I have two main tasks as Independent Complaints Reviewer for Land Registry. The first is to investigate and resolve individual complaints about Land Registry and the second to make recommendations based on the lessons of those complaints.
To succeed in the role I have to tread a fine line – remaining firmly independent of Land Registry while also making sure that I am up to date with Land Registry procedures, policies and strategy.
From this position I am able to make fair and objective findings on the cases I investigate, and also to make proposals for change that are realistic and practical from Land Registry’s point of view.
Land Registry’s own measures show that the great majority of customers are happy with the service they receive. The complaints that reach me therefore are unusual. But unusual cases are the ones that reveal the strengths and weaknesses of an organisation. Each one offers a valuable opportunity to look in detail at what has happened and to identify what has gone well as well as what may have gone wrong.
Land Registry staff are strongly committed to customer service. In my experience the cases that produce justified complaints involve human error, difficulties in communicating complex legal points, or weaknesses in procedures or guidance, rather than any intention to be unhelpful.
As I set out in my annual report, my office received 142 complaints during 2015/16, up from 139 the previous year. Six were resolved through intervention and I investigated 59. Of these 16 were fully or partly upheld, up from 15 the previous year.
The complaints I investigated covered many aspects of Land Registry’s work. Some shone new light on points that I have highlighted before – for example the fact that many people still do not appreciate what Land Registry can and can’t do.
Other complaints raised new issues – regarding the use of online services by non-professionals, and what customers are hoping for when they make a complaint of delay. There have also been some systemic problems with Land Registry’s complaints procedure.
I made 35 recommendations to Land Registry during the year, of which 37 per cent were for an apology, 20 per cent were for a consolatory payment and the remainder for a review of procedures or guidance, a reminder to staff of existing procedures and guidance, or a review of or improvement in public information.
There is little point in my making recommendations unless there is an expectation that Land Registry will implement them. Land Registry’s Independent Complaints Reviewer Evaluation and Study Team (ICREST) plays a vital role here – examining every report and recommendation and deciding how to take them forward.
During the past year ICREST has confirmed that, as a result of some of my recommendations:
- Land Registry has prepared new guidance for the public to answer questions about its requirements when applicants have to provide evidence of their identity
- notices have been rewritten to include information which I considered helpful and which was formerly included on GOV.UK
- wording on GOV.UK regarding feedback on price paid information has been clarified
- staff have been reminded of the importance of addressing all points raised in correspondence and, where appropriate, explaining why Land Registry cannot provide an answer on a particular point
- new training on how to identify and deal with complaints will be provided to all members of staff
- new guidance for the public has been prepared to answer questions about general boundaries.
New targets for ICREST say Land Registry will respond within two weeks to any recommendation for an apology, and ICREST will agree action plans for implementation of systemic recommendations within four weeks of its next meeting and then complete the agreed actions within 10 weeks where possible.
This is a very welcome development, providing assurance that the lessons of complaints will make a real difference for Land Registry’s customers.